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Section 148

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ITAT Deletes On-Money Addition as Unsigned Agreement & Third-Party Records Lacked Evidence

Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...

June 30, 2026 333 Views 0 comment Print

Rectification, Assessment and Appeal under Income Act, 1961

Income Tax : Learn the updated provisions governing rectification, assessments, reassessments, and appeals under the Income-tax Act. This guide...

June 29, 2026 14058 Views 0 comment Print

Can Updated Return Be Filed After Notice Under Sections 143(2), 148A or 148?

Income Tax : The article explains how the Finance Acts, 2025 and 2026 have reshaped the Updated Return regime under Section 139(8A). It highlig...

June 27, 2026 2823 Views 0 comment Print

SC Sends JAO vs Faceless Reassessment Dispute Back to High Courts

Income Tax : The Supreme Court has remitted reassessment cases for fresh consideration after the retrospective insertion of Section 147A, leavi...

June 27, 2026 498 Views 0 comment Print

Appellate Kill Shot to Reassessment Notices Under Section 148/148A

Income Tax : This article explains why reassessment proceedings may be invalid if the Assessing Officer merely relies on Investigation Wing rep...

June 20, 2026 1053 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2469 Views 0 comment Print

Budget 2024: Amendments to Income-tax Assessment & Reassessment Provisions  

Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...

July 23, 2024 4584 Views 0 comment Print

Request to amend section 151 Sanctioning Authority for reassessment

Income Tax : Humble Representation for modification of Section 151 of the Income Tax Act relating to Sanction for issue of Notice under sec. 14...

July 25, 2022 6918 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 7524 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 13395 Views 0 comment Print


Latest Judiciary


Unaccounted sales must be taxed on net profit basis, not on gross profit

Income Tax : Where unaccounted sales were established through seized material, only the net profit embedded therein was liable to tax, and not ...

July 7, 2026 258 Views 0 comment Print

Section 56(2)(x) Applicability Depends on Agreement Date; Mistaken Tax Payment Refundable: ITAT Mumbai

Income Tax : ITAT Mumbai remanded the case to examine whether Section 56(2)(x) applied based on the agreement date and to consider refund of ex...

July 6, 2026 615 Views 0 comment Print

APMC Commission Agent Not Taxable on Entire Sale Proceeds; Section 69A Issue Remanded: ITAT Bengaluru

Income Tax : ITAT Bangalore remanded a Section 69A addition after holding that an APMC commission agent's entire sale proceeds could not be tre...

July 6, 2026 285 Views 0 comment Print

1439-day delay in Filing Appeal Condoned & Matter Remanded for Fresh Assessment: ITAT Kolkata

Income Tax : ITAT Kolkata condoned appeal delay, set aside the CIT(A)'s order, and remanded the assessment for fresh adjudication after grantin...

July 5, 2026 285 Views 0 comment Print

Section 143(2) Notice & Valid Draft Assessment Mandatory U/s 144C: ITAT Mumbai

Income Tax : ITAT Mumbai quashed reassessment after finding no Section 143(2) notice and that the AO issued a final order disguised as a draft ...

July 5, 2026 228 Views 0 comment Print


Latest Notifications


Income Tax Dept Flags High-Risk Transactions for Reassessment Action – Sections 148/148A

Income Tax : The department has identified high-risk cases through its Insight Portal for AYs 2022-25. It directs officers to initiate reassess...

March 20, 2026 1272 Views 0 comment Print

ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 5961 Views 0 comment Print

Guidelines for issuance of notice u/s 148 of the Income Tax Act, 1961

Income Tax : Explore the latest guidelines for issuing notice under Section 148 of the Income Tax Act, 1961. Understand key procedures, amendme...

June 28, 2024 58935 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 6018 Views 0 comment Print

Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5985 Views 0 comment Print


AO’s Own Penalty Order Sinks Reassessment: ITAT Holds First Section 147 Order ‘Infructuous’

May 11, 2026 273 Views 0 comment Print

The Tribunal ruled that the Income Tax Department cannot pass two reassessment orders for the same assessment year, same transaction, and same addition. The first reassessment proceedings were held legally unsustainable.

SEZ Lease Rentals Are Business Income, Not House Property: ITAT Mumbai

May 11, 2026 294 Views 0 comment Print

The Mumbai ITAT reaffirmed that lease rentals from SEZ and IT Parks along with amenities are taxable as business income. The ruling relied on CBDT Circular No. 16/2017 and multiple judicial precedents supporting taxpayers.

Reassessment Notice Quashed as Fresh Section 148 Notice Was Time-Barred: ITAT Delhi

May 9, 2026 411 Views 0 comment Print

The ITAT Delhi held that reassessment notices issued after expiry of the surviving limitation period under the amended reassessment regime were invalid. The Tribunal quashed the reopening proceedings and related penalties for both assessment years.

Entire Bank Deposits Cannot Be Taxed as Income – ITAT Restricts Addition to 2% in Renukamata Society Cases

May 9, 2026 1677 Views 0 comment Print

The Pune ITAT held that entire cash deposits in bank accounts cannot automatically be treated as unexplained income when the assessee appears to be only a conduit in an accommodation entry network. The Tribunal restricted the taxable addition to 2% of deposits after finding no evidence of actual enrichment.

No Addition, No Under-Reporting: ITAT Deletes Section 270A Penalty When Income Returned u/s 148 Was Fully Accepted

May 8, 2026 825 Views 0 comment Print

Pune ITAT held that penalty for under-reporting of income cannot survive where the Assessing Officer accepts the income declared in response to notice under Section 148 without any addition. The Tribunal deleted the entire penalty under Section 270A.

Section 69B Addition Confirmed as AO Recorded Discrepancies Before DVO Reference

May 8, 2026 300 Views 0 comment Print

Madras High Court held that a reference to the District Valuation Officer was valid because the Assessing Officer had effectively rejected the books of accounts after recording discrepancies. The Court upheld the Section 69B addition for unexplained investment in building construction.

Reassessment Beyond 3 Years for ₹8 Lakh Addition? – ITAT Questions Validity of Section 148 Notice

May 8, 2026 315 Views 0 comment Print

Pune ITAT observed that reassessment proceedings initiated beyond three years may not be maintainable where the alleged escaped income is below ₹50 lakh. The matter was remanded for verification of jurisdictional facts and statutory notices.

ITAT Remands Section 69A Addition as CIT(A) Failed to Pass Proper Speaking Order

May 8, 2026 417 Views 0 comment Print

ITAT Kolkata set aside the appellate order after observing inconsistencies between the findings of the CIT(A) and the assessment order. The Tribunal directed fresh adjudication with a reasoned speaking order and proper opportunity of hearing.

Bogus Purchases Fully Disallowable as Supplier Was Found Non-Existent: ITAT Kolkata

May 8, 2026 921 Views 0 comment Print

ITAT Kolkata held that entire bogus purchases must be added under Section 69C where the supplier was proved to be a paper entity and no evidence of actual delivery of goods existed. The ruling reiterates that bank payments and invoices alone cannot establish genuineness.

No Evidence Linked Assessee to On-Money Transaction: Gujarat HC Quashes Section 148 Notice

May 7, 2026 426 Views 0 comment Print

Gujarat High Court held that reassessment proceedings could not continue where Revenue failed to establish any independent material connecting assessee to alleged cash transactions. Section 148 notice based solely on a broker’s seized register was quashed.

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